Scott, Paul Affidavit.pdf

AFFIDAVIT OF PAUL SCOTT
I, Paul Scott, under penalty of perjury, declare and state:
1. I am forty-five (45) years old and was born on May 31, 1967.
2. I am the founder, President and Chief Science Officer of Scott Analytics, Inc., a
company that provides internal anti-doping programs for professional cyclists and other non-
cycling events.
3. I do not presently, nor have I ever held a license from the Union Cycliste
Internationale (“UCI”).
4. The statements contained in this affidavit are based on my personal knowledge
and are true and accurate.
5. I am providing this affidavit to the United States Anti-Doping Agency (USADA)
as part of my voluntary cooperation with USADA and as a part of USADA’s investigation of
doping in the sport of cycling.
6. I understand that this affidavit will be submitted in legal proceedings, including
arbitrations, in which USADA is presently involved or may become involved, and in connection
with cases that USADA has brought, or may bring, in connection with doping in the sport of
cycling.
7. USADA has full authority to use this affidavit as appropriate in connection with
its anti-doping responsibilities under the Code, including use in any legal proceedings or in
connection with any decision or announcement of sanctions or violations issued by USADA.

8. The testimony and statements provided in this affidavit were provided directly to
USADA and have not previously been provided to the UCI or USA Cycling.
9. I have known Floyd Landis for approximately six years.
10. In early April of 2010, I received a call from Floyd.
11. Floyd told me that he was considering coming clean about his use of performance
enhancing drugs during his cycling career and wanted me to help him get the information to
someone at USADA who could act on the information.
12. I told Floyd that I had a good relationship with Daniel Eichner, the Science
Director for USADA, and that I would reach out to Daniel to see if USADA would be interested
in what Floyd had to say.
with Floyd.
13. I called and spoke to Daniel on the phone within a day or so of my conversation
14. I told Daniel that I had recently been contacted by an elite professional cyclist
who provided me with information about doping activities engaged in by him and others while
he was riding for high profile cycling teams. I explained to Daniel that the cyclist was
considering going public with the information and that he had asked me to contact USADA and
pass along information he had given me.
15. The information I shared with Daniel during the phone call was high-level in
nature but I did specify that the cyclist had information about systemic doping on the U.S. Postal
Service team and that the he had engaged in doping activities with several elite cyclists,
including Lance Armstrong, Levi Leipheimer and David Zabriskie.
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16. I told Daniel that the cyclist was willing to meet with USADA but did not
disclose that Floyd was the cyclist. Still, by the end of our conversation, I believe it was obvious
who had provided me with the information given my known relationship with Floyd.
17. After I gave Daniel an overview of Floyd’s information, we made arrangements
to meet in person the following Monday so that I could provide Daniel with more details about
Floyd’s knowledge and experiences concerning the use of prohibited substances and methods in
professional cycling. Daniel flew into town a couple days later and we met at my home office to
resume our discussion on the morning of April 12, 2010.
18. During our meeting, I confirmed that Floyd was my source and provided Daniel
with Floyd’s description of the U.S. Postal Service doping program and information about the
various riders, support staff, team officials and others who were actively involved in carrying out
the system.
19. I cannot speak, now or then, to the veracity of the information contained in
paragraphs 20 to 24 except in so far as it was the information I relayed to Daniel as having come
from Floyd. As to the truth of the allegations, I have no personal knowledge. To the extent that
any paragraph, or sentence, reads as if I had or have personal knowledge, that is not that case.
All information provided to Daniel was provided at the request of Floyd and represents
information about which Floyd represented to me he had personal knowledge.
20. I told Daniel that Floyd admitted to using EPO, testosterone and hGH supplied to
him by U.S. Postal Service team doctors and staff members. I specifically recall telling Daniel
that Dr. del Moral and “Pepe” Marti administered and/or supplied Floyd with banned
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performance enhancing substances during his time with the U.S. Postal Service team. I also told
Daniel that the U.S. Postal Service team Director, Johan Bruyneel, had several conversations
with Floyd about the team’s doping program and had either facilitated the procurement of or
provided Floyd with EPO on at least one occasion.
21. Floyd provided me with information about the use of autologous blood
transfusions on the U.S. Postal Service cycling team and I shared that information with Daniel as
well, including how the blood was stored and transported and the various individuals involved in
executing the procedure. I specifically recall relaying Floyd’s account of how the U.S. Postal
Service team bus pulled to the side of the road after a stage of the Tour de France and faked a
mechanical breakdown so that several members of the team could receive blood transfusions on
the bus.
22. Floyd provided me with a list of the riders whose doping activities he had
witnessed first-hand prior to my meeting with Daniel. I do not remember all of the riders on the
list, but I do recall that Lance Armstrong, Levi Leipheimer, David Zabriskie, and George
Hincapie were identified. I told Daniel that Floyd told me he had either personally doped with,
helped to dope or, in the case of Lance, been provided with doping materials by each of the
riders on the list.
23. I also told Daniel about Floyd’s relationship with Dr. Ferrari and that Dr. Ferrari
was very involved with Floyd’s doping program while Floyd was riding for the U.S. Postal
Service team. I specifically remember telling Daniel that Dr. Ferrari’s standard fee to work with
a rider was ten percent (10%) of the rider’s annual contracted salary.
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24. After the April 12 meeting, 1was present, at Floyd's request, during a meeting
among, Floyd, Daniel and USADA CEO Travis Tygart in Los Angeles, California, on April 20,
2010. During the April 20 meeting, Floyd relayed ail of the above mentioned information, and
additional information regarding his experiences and personal knowledge of doping in cycling,
directly to Travis and Daniel.
25. This affidavit is not an exhaustive summary ofmy testimony; however, it fairly
and accurately sets forth information within my personal knowledge.
1 swear or affirm that the foregoing statements are true to the best of my knowledge,
information and belief.
Dated this 9 th day ofOctober, 2012.
STATE OF CALIFORNIA )
) ss.
COUNTY OF _
)
Subscribed and sworn to before me by on this day of 20 12.
Witness my hand and official seal.
Notary Public
Address:
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CALIFORNIA JURAT WITH AFFIANT STATEMENT GOVERNMENT CODE § 8202
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